Applicants should maintain an appropriate anti-money laundering and counter-terrorist financing framework aligned with the scale and risk profile of their operations.
AML / CFT controls are intended to help operators identify suspicious activity, monitor financial flows, and maintain appropriate safeguards against illicit financial activity.
Applicants should demonstrate that AML controls exist not only as written policies but also as operational procedures supported by monitoring, reporting, and oversight.
Operators should implement appropriate onboarding controls designed to establish the identity of customers and verify relevant information before permitting certain account activities.
Customer due diligence procedures may include identity verification, account profiling, and risk-based monitoring depending on the nature of the business model.
Monitoring mechanisms should identify unusual behaviour patterns, rapid deposit and withdrawal cycles, irregular betting activity, or other anomalies that may indicate potential misuse of services.
Monitoring controls should be supported by defined escalation pathways and appropriate internal review procedures.
AML oversight responsibilities should be clearly assigned within the organisation. Applicants should be able to demonstrate who is responsible for monitoring, reviewing alerts, and maintaining internal reporting processes.
Records relating to AML monitoring, alerts, and investigations should be retained for an appropriate period and maintained in a manner that supports auditability.
A written AML policy without operational evidence, monitoring rules, or escalation workflows does not constitute a functioning compliance framework.
